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Neutral Citation: [2024] UKUT 00110 (TCC)
Case Number: UT/2021/000157
UPPER TRIBUNAL
(Tax and Chancery Chamber)
Rolls Building, London
CAPTAL GAINS TAX – whether FTT erred in concluding taxpayer’s transfer of the beneficial interest in distribution rights in company (where the company’s articles did not provide for transfer of those rights) was a disposal – no – appeal dismissed
Heard on: 27 February 2024
Judgment date: 01 May 2024
Before
JUDGE SWAMI RAGHAVAN
JUDGE VIMAL TILAKAPALA
Between
JOHN TENCONI
Appellant
and
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant: The Appellant
For the Respondents: Stephen Donnelly, Counsel, instructed by the General Counsel and Solicitor to His Majesty’s Revenue and Customs
DECISION
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